Open letter to IMF: Former officials and experts urge not to block changes to PEP status in Ukraine
Former Ukrainian officials, experts, and representatives of the business community and civil society have published an open letter to the International Monetary Fund calling on it to support amendments to legislation on politically exposed persons (PEPs). The authors of the document argue that the new provisions comply with FATF standards, introduce a risk-based approach, and should not provide grounds for restricting international support for Ukraine.
Censor.NET reports this, citing a Facebook post by Svitlana Panaiotidi.
The letter is addressed to IMF Managing Director Kristalina Georgieva. Copies were also sent to the European Commission, European Commissioner for Enlargement Marta Kos, EU Ambassador to Ukraine Katarína Mathernová, and Deputy Prime Minister for European and Euro-Atlantic Integration of Ukraine Vsevolod Chentsov.
What the letter says
"The purpose of this letter is to set out a reasoned objection to the IMF’s concerns about the adopted amendments to the legislation governing politically exposed persons, which paragraph 45 of the June Memorandum describes as weakening the effectiveness of the PEP regime and bringing Ukraine’s AML/CFT system out of compliance with FATF standards, and to explain why these amendments should be supported and adopted without delay," the post reads.
Substance of the amendment
On Tuesday, 9 June 2026, the Verkhovna Rada of Ukraine adopted in the second reading and as a whole draft Law No. 15111-d on the taxation of income from digital platforms. As part of the vote, an amendment was approved reducing the period of mandatory enhanced financial monitoring of politically exposed persons to 12 months from the date on which they leave the relevant position.
The amendment provides for the following:
1. A clear mechanism is introduced requiring banks and other primary financial monitoring entities to reassess risks 12 months after a person ceases to perform PEP functions.
2. Enhanced monitoring is not abolished: banks retain the right and, where risks exist, the obligation to continue enhanced due diligence and monitoring after the 12-month period has expired.
3. The amendment eliminates a longstanding gap in the Law of Ukraine "On Prevention and Counteraction to Legalisation (Laundering) of Proceeds of Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction": a general provision on reassessing risks after 12 months already existed but lacked a clear implementation mechanism, accountability and practical application.
4. The amendment ensures a genuinely risk-based approach, the cornerstone of FATF recommendations, instead of the automatic lifelong application of enhanced measures regardless of the actual level of risk.
Compliance with FATF standards
The amendment does not contradict any FATF recommendation or standard. FATF Recommendation 12 and its related interpretive notes specifically emphasise a risk-based approach to PEPs and do not require lifelong enhanced monitoring regardless of how much time has elapsed.
We have the relevant FATF documents and are prepared to provide detailed references to them. To date, neither the IMF nor its Ukrainian counterparts have identified any specific clause, recommendation or provision that the amendment allegedly violates or explained the substance of the alleged violation.
The signatories emphasise that the revised legislation introduces a risk-based approach which, they say, is consistent with FATF recommendations and does not contradict international standards. They argue that no specific FATF provision allegedly violated by the adopted amendment has yet been publicly identified.
According to the authors of the appeal, the current practice means that former officials, as well as their family members and business associates, are subjected to equally stringent financial monitoring procedures for years without any risk reassessment. The consequences they cite include regular checks, repeated customer identification, difficulties opening accounts and obstacles to conducting routine financial transactions.
The letter separately notes that lifelong PEP status negatively affects public administration reform by discouraging highly qualified professionals from working in the civil service, on supervisory boards and in other public bodies.
Substance of the request
1. Obtain an objective and detailed analysis of the amendment from a range of stakeholders (including business associations, civil society and independent experts) in light of the actual FATF standards.
2. Begin a direct professional dialogue, including by videoconference, with the aforementioned stakeholders and the signatories to the letter regarding the results of the analysis of the amendment.
3. Refrain from blocking support or making it conditional on reversing this justified, risk-based adjustment until a proper evidence-based assessment has been completed.
"Ukraine needs effective, not performative, AML/CFT regulation. A system that burdens law-abiding citizens and businesses but fails to identify actual criminals serves neither the goals of transparency nor the interests of the Ukrainian people.
"We remain open to dialogue and are prepared to provide detailed explanations of how this provision works in practice, relevant excerpts from FATF documents and specific examples of problems caused by the previous approach," the letter reads.
The letter has already been signed by 60 Ukrainian citizens who have held various public positions and who, together with their family members, are subject to lifelong PEP status, as well as experts and representatives of civil society and the business community.
How to sign
The open letter remains available for signatures. Its authors said they plan to send the document to the IMF in English, together with a list of all signatories who join the appeal.
